In
Golden Road Motor Inn, Inc. v. Islam, 132 Nev. 476, 488, 376 P.3d 151, 159 (2016), the Nevada Supreme Court held that district courts cannot, on their own, blue-pencil a noncompetition agreement to remove unreasonably restrictive, and thus unenforceable, aspects.
SeeNevada Supreme Court Refuses To Blue Pencil Unreasonable Non-Compete The Nevada legislature was not in accord and the following year enacted NRS 613.195, which requires district courts to blue-pencil unreasonable noncompetition agreements and enforce the revised agreement. 2017 Nev. Stat., ch. 324, § 1, at 1861. That would seem to be the end of the story, but it wasn t. Left unanswered was the effect of NRS 613.195 on agreements entered into before the statute was enacted.
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